ML20062B386

Forwards Memo Presenting Util Opinion on Treatment of Decommissioning Funding for Prematurely Shutdown Nuclear Plants

ML20062B386
Person / Time
Site:	Rancho Seco
Issue date:	10/17/1990
From:	Scott Freeman SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
GM-90-777, NUDOCS 9010240339
Download: ML20062B386 (17)

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SACRAMENTO MUNICIPAL UTIUTY DISTRICT O 6201 S' Street, P.O. Box 15830. Secremento CA 95852-1830. (916) 452 3211 AN ELECTRIC SYSTEM SERVING.THE HEART OF. CALIFORNIA. -

l October 17, 1990 l

GM'90-777-f i

James.M. Taylor

' Executive Director For Operations United States Nuclear Regulatory Commission-Washington, DC 20555~-

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Dear Director Taylor:

Thank you for allowing.me to present the District's opinion on the treatment of timing of Decommissioning Funding for Prematurely Shutdown-Nuclear Plants.

'l As we' discussed in our meeting on October 17, 1990, I have attached a copy;of a' memorandum from-the District's. Counsel analyzing.the appropriate NRC staff treatment for this timing.

I appreciate this opportunity to reiterate our position on this Lissuewhich is. of extreme impo'.tance to the customer / owners of the i

District, i=

Sincerely,

'aw y

S. David Freeman General _ Manager Attachment l

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RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road, Herald, CA 95638 9799;(209) 333 2935

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.TO:

S.. David Freeman, General Manager

-.1 Sacramento Municipal Utility Distri'ct FROM:

Thomas.A. Baxter David R. Lewis l-

SUBJECT:

Decommissioning Funding Accumulation Periods for Prematurely. Closed Nuclear Power Plants

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DATE:

October 16, 1990 s

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Introduction

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This memorandum examines how the Nuclear Regulatory-Commission (NRC) should treat the timing of decommissioning funding for. prematurely shut down nuclear plants.

Because the I

NRC's regulations do not address this' issue squarely, and in ilight of the premature shutdowns of the Shoreham, Fort St. Vrain, and. Rancho Seco facilities, we understand that the NRC Staff-is seeking Commission guidance on three options: (1) immediate

-funding; (2) funding over five years; and (3) funding through'the end of the' license term.

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-As discussed below, we strongly recommend that the Staff 1not.

-t seek such a decision from the Commission, and that the Commission 1

-not limit 1the_NRC Staff's discretion to choose among-the three.

proposed ~ options, or other possible options for that matter.

Instead, the Staff should be left with the authority and L

flexibil-ity to consider the timing of decommissioning funding for prematurely. shut down plants on a case-by-case basis,_and to~

fashion a' decommissioning funding schedule that considers the particular circumstances of'the licensee.

We believe that this type of flexibility meets the NRC's intent underlying.Its decommissioning rule.

The decommissioning 1

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rule?was intended to-be a flexible regulation -- one thati provided~. reasonable assurance that funds would be-available,for l;

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decommissioning _when needed without imposing undue financial burdens on the licensees.

These precepts-militate against l-limiting options and toward individual considera' tion of' the

.particular. circumstances presented by a prematurely shut down plant.

Only by this-means can-the NRC arrive at a course that provides the requisite reasonable assurance of funding without imposing' undue' burdens.

In one individual case, the NRC might-determine that accelerated funding is appropriate, but in another, where there is sufficient assurance of ultimate funding, a longer term of accumulation might be in order.

Rancho Seco.

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_provides a good illustration of the latter, being a state agency that cannot become bankrupt and that has the '.egal' authority to establish its own rates to cover costs.

If,-on the other-hand, the Lemmission is' inclined to preselect a particular option _and-limit the discretion of the Staff, we believe that it may only do so in a rulemaking

. proceeding.

The Commission would be establishing substantive:

obligations, which under the Administrative Procedure Act (APA),

must be preceded by notice and opportunity for comment..

The basis fcr these recommendations and conclusions is presented.below.

First, a brief overview of the decommissioning rule and its purposes is discussed. 'Then, the pertinent policy considerations are examined, and Rancho Seco's situation described to place the issue in context.

Finally, the procedural requirements of'the APA are briefly addressed.

II. ' Overview of the Decommissionino Rule Under 10 C.F.R.

S 50.75(c) and (e), the licensees of nuclear plants are required to establish decommissioning funding mechanisms, such as an external sinking fund.

A licensee who is an electric utility'may use a generic " certification" amount

. prescribed in the NRC rule as the initial funding target.

Five years before the " projected" end of operations, such licensees A

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are' required to submit a preliminary decommissioning. plan-which' 1

'"shall also include plans for adjusting levels of funds assured for decommissioning to demonstrate that a reasonable level of assurance will be provided that funds will be available when needed to cover the costs of decommissioning."

10 C.F.R. 5150.75(f)..The proposed decommissioning plan itself (due within

.two years fol' lowing' permanent cessation of operations, and in no

-1 case later than_one year prior to expiration of the operating

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license) must include a'" plan for assuring the availability of adequate funds for completion of decommissioning."

10 C.F.R.

S'50.82(b)(4).

The NRC'has explained that i

1 Consideration of these steps, first establishing a general level of adequate i

financ'ial.responsibil'ity for. decommissioning early in life, followed by periodic adjustments, and then evaluations of specific provisions close-to the: time of decommissioning, will provide reasonable L. = c assurance that the Commission's' objective is l

met,'namely that, at the time of permanent l

end of operations sufficient funds are available to decommission the' facility in a manner which protects the public health and l

safety.

53 Fed. Reg. 24,018, 24,030-31 (1988).

The Federal Register statement reflects.the NRC's

" objective" that sufficient-funds be available at the time of i i

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SHAw, PITTMAN, PoTTs & TROWBRIDGE a p*=rucasme iwcwo. o==orsseio=46 con.oancas permanent end of operations.- The Federal Register statement and rule a' Iso make.'it-clear that the rule contemplates such funding over a normal period of operation, commencing with a " general

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early in life" followed by adjustment five years before the " projected" end of operations.

Similarly, in Public Service Co. of New Hampshire (Seabrook Station, Units 1 and 2),

CLI-88-10, 28 N.R.C. 573, 584-85 (1988), the Commission explained:

The' decommissioning rule was issued to ensure

'that at the conclusion of the lengthy period in which reactors would be in commercial operation there would be funds available for safe and timely decommissioning.

.(T]he rule contemplated a step-by-step decommissioning funding assurance process 1

over a long period of time with an-initial l

certification of funding, periodic updates, a preliminary decommissioning plan at or about 5' years before projected end of operat-ions, and a decommissioning plan submitted as part of the application for licensing termination.

The description in the rule itself of the allowable funding methods indicates such methods should-be initially structured to accumulate sufficient decommissioning funding by the time. _ _ _ - _

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The plan.that a; licensee'must-submit five years before the projected end of operation,. however, need demonstrate only that there is a

" reasonable level of assurt.nce" that funds will be available "when'needed'to cover the costs-of decommissioning."

See 10 C.F.R. S 50.75(f).

There is no provision in the rule stating that.a licensee shall have all the funds it needs for decommissioning at the time it ceases operation.

If a-licensee chooses.to use the SAFSTOR method of decommissioning, 10 C.F.R.

S 50.82(c)(1) does require that.the licensee's decommissioning plan include a provision that " funds needed to complete decommissioning be placed into an account segregated!from the. licensee assets and outside the licensee's administrative control during the storage or surveillance period.

As explained.more fully below, however, this provision was not written to apply to premature 1'y_ shut down plants, but rather to those which operate for a normal reactor.

life.

The rationale behind section 50.82(c)(1).is that there'i.s a need'for assurance of funds over the extended timeframe when a 1/

For example, an external sinking fund is defined as a fund established and maintained by setting funds aside periodically-in an account segregated from licensee assets and outside:the licensee's administrative control in which the total amount of funds'would be sufficient to pay decommissioning costs at the time termination of operation is expected.

10 C.F.R. S 50.75(e)(1)(ii). I,

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facility is no longer a revenue producing asset.

53' Fed. Reg.Lat 24,034; NUREG-'1221 at D-31.

In addition, this provision serves to protect against the possibility of licensee-bankruptcy during-

a. lengthy storage period.

NUREG-1221 at B-13, D-31.

L

-t Even this provision.is not1a self-effectuating requirement

.for full funding by a specific date.

The storage period may

.1 post-date termination of operations by years, and indeed there is nothing in.the NRC's regulations that requires the licensee'to enter the storage period during the term of its license.

Further, the amount that must be set aside to " complete"

' decommissioning arguably could be less than the total estimated amount by. excluding storage costs.

The absence of an absolute. requirement to fully fund

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decommissioning costs by specific. dates, such as the time a plant ceases operation, is not surprising.

The provisions in 10 C.F.R.

F 55.50.75 and 50.82 are primarily. intended to require, appropriate planning, both financial and. technical, which the NRC Staff then reviews.

Thus, a licensee's firm legal obligations become Ldefined by its commitments in approved plans required by the b m

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The ' objective to fund the decommissioning 1iability by the

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end of operations is a reasonable planning criterion for normally y

operating reactors generally.

Because existing operating

, reactors have from about twenty to forty years lef t befor e their t

' licenses expire, the licensees may accumulate funds gradually.

-However, because it is not possible to foresee the precise

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situation of licensees twenty to forty years hence, or the method 4

or timing of decommissioning such licensees may select, the long-L term planning criterion aims for sufficient-funding by the

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projected end of operations.

This criterion as applied to reactors operat-ing normally over their expected lives: reasonably hi

' balances financial assurance against burden.

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-In addition,:the.NRC structured its rule to provide.

flexibility.

As,was noted during:the_rulemaking, o

The rule provides a framework for the regulation of decommiss'ioning which is adequate for decommissioning after normal

' operations or after an accident.

This flexibility allows for case-by-case 1

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A licensee should not be in violation of any regulation if decommissioning costs turn out to be greater than the amount accumulated pursuant to an approved plan.

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4 C-considerat' ions-'which are especially important-in, dealing with;an accident situation.

NUREG-1221 at C-14.

Finally, the decommissioning rule reflects the Commission's

-endeavor to. minimize the' administrative-effort of 1-icensees and-to avoid' imposing undue financial burdens.

See'53 Fed. Reg..at

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24,030, 24,033 ("the Commission believes it is'important not tof

impose inordinate financial burdens on'11censees.") 'This k

sensitivity was manifested in the NRC's decision not to develop

. financial assurance-mechanisms in anticipation'of prematurely

- shutdown plants. : The CommissionJspecifically rejected comments 7

. calling for the prepayment of-funds as a gu'ard against-premature' shutdown.

An important consideration-in selecting an acceptable method for providing funds for decommissioning is that the method be reasonably cost-effective.

Prepayment'of-funds has been recognized-by several' studies 1

as being'significantly'more expensive-than-other methods.

'In view of the=unlikely-nature of the. event being considered (i.e.,

L' premature shutdown),. prepayment generally has a cost too high for the benefit thatLwould be realized.

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' 5 3 -Fed. Reg.: at.24,034.

See also NUREG-1221 at D-24.

In the same vein, the NRC did not include in the final rule the "make

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NUREG-1221-at D-35 to D-36..

III. Application of the' Decommissioning Rule to Prematurely Shutdown Plants As noted by the NRC Staff in review of Fort St. Vrain's t

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.prema ure c osure, y

l In considering the final decommissioning rule, the Commission assumed that power reactor licensees would be able to accumulate L'

funds over the full operating life of the l-plant as determined by the remaining term of.

l the operating license.

It does not appear,

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.however, that the-Commission meant to force-those licensees.who cease operation prematurely to raise the entire amount of required decommissioning-funds at the time of

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shutdown.

1 Letter from P.

Erickson to A. Crawford, Docket No. 50-267, " Fort L

St. Vrain, Decommissioning Financial Plan and Preliminary J

. Decommissioning Plan -- Request for Additional Information" (Oct.

4, 1989). 'The Staff proceeded to state its determination that-

- the NRC should allow that licensee "some leeway in the time i

permitted to collect decommissioning funds."

In that case, the Staff suggested funding through the license term (until 2008).

Indeed, it should be noted that the decommissioning rule is L

-written in a manner that makes literal compliance impossible for a prematurely shutdown plant.

A prematurely shutdown plant will.-

j SH Aw, PITTMAN, PoTTs & TROWBRIDGE

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'I notlhave submitted-an updated financial plan five years before the end of operations and may not have-the decommissioning' cost estimate that~would be part of the submittal.

Further, even if the utility had a site-specific decommissioning cost estimate, it would be extremely improvident for the NRC to insist on immediate deposit of the full amount.

Rather_ than increasing financial assurance, NRC insistence on immediate deposit of a sum on the order of one to several hundred million dollars could create financial instability.- At the ver/

least, it would:cause the utility to draw upon resources that might be'better spent for defueling, plant layup, prompt waste disposal, and other activities conducted immediately-following cessation of operations to place the facility into a secure non-l-

operational condition.

In sum,.while full funding by the end of operations was a reasonable'long-term planning criterion for normally operating

.i reactors, it is probably not an appropriate requirement for prematurely shut down plants, as the Staff already has recognized in its. Fort St. Vrain review.

The balancing of benefits and burdens that the NRC undertook when considering what licensees should do in general -- licensees who were expected to operate their plants for at least another twenty years -- does not apply to a prematurely shut down plant.

The burden of immediate or l,

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even short-termLfunding may be inordinate, not only threatening the stability of the licensee but severely impacting-the ratepayer and'the competitiveness of the local economy.

At this juncture, careful consideration is necessary to determine what is reasonable in light of the specific circumstances.

-Clearly, then, it is appropriate to allow a licensee of a prematurely shutdown facility some reasonable period to accumulate funds.

What is a reasonable period will depend on the L

specific circumstances -- how much needs to be accumulated, when the funds will be needed, and the degree of financial security-of 4

the licensee.

The particular circumstances may very well justify i

an accumulation period in excess of five years.

i-s The Rancho Seco situation is an apt illustration.

SMUD, l

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-which shut'down Rancho Seco after a June 6, 1989 referendum, has

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1 committed to an. initial der.osit of $55 million for its external.

decommissioning sinking fund.

See letter from D.'Keuter to NRC, Docket No. 50-312, " Decommissioning ~ Financial Plan and Interim f

Exemption Request from Certain Requirements of 10 C.F.R. 50.75(e)(1)(ii)" (July 24, 1990).

SMUD is still evaluating decommissioning options and investigating costs, and has not yet filed a site-specific decommissioning cost estimate.

While the-District' submitted to the NRC on July 12, 1990, a status report-onzdecommissioning planning for Rancho seco (" Plan for Ultimate :. o ei,

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. Disposition of the Facility"), it has: not yet filed a: proposed:

j decommissioning-plan under 10 C.F.R. S 50.82.

While it,is likely

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'that SMUD will propose a storage period of several decades and a funding plan consistent with the timing of major expenditures for decommissioning activities, the NRC should wait for such information, in the form of. plans, before deciding on a major element of the financial scheme.

The funding accumulation period,

.should'not be decided in the abstract, but along with the decommissioning plan,-the site specific cost estimate, and the i

revised financial plan.

A generic policy would not allow the Staff to take into consideration SMUD's ability to generate funds over a long period 4

of time, which is well assured by several factors.

First, SMUD

-maintains multiple generation facilities, power purchase

-contracts, as well as extensive transmission-and distribution 1

facilities.

Consequently, its revenue producing' capability and financial stability are not wholly dependent on Rancho Seco.

Further, SMUD has the statutory authority under California's Municipal Utilities District Act to establish the rates for.the power it. sells, and therefore the legal authority to recover its costs from the ratepayers irrespective of whether a particular t

asset is used and useful.

In addition, further assurance of-adequate decommissioning funding is provided in SMUD's case L/3 5

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i because of: California's Nuclear Facility Decommissioning Act, which imposes a separate and independent State requirement-to fund decommissioning expenses.

Finally, SMUD as. a municipal utility district is precluded f rota bankcuptcy-in the usual sense.

Instead,- the Bankruptcy Code allovs for a municipal-reorganization" where the municipal's liabilitiea and obligations

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must eventually be paid.

These same considerations would. justify in SMUD's case the accumulation of funds into the storage period and beyond the license term.

The planning criterion to segregate during the.

storage period funds to complete decommissioning was based on the' l

concern that the licensee might not be able'to generate further funds if its nuclear plant was no longer'a revenueLproducing asset and on the concern that the licensee might become~ bankrupt

'during the period.

Neither concern would pertain to SMUD,

.because again SMUD has its own authority to establish rates to cover costs, including the costs of' decommissioning a retired plant, and because SMUD cannot avoid its obligations by bankruptcy.

IV.

Limitations Imposed by the Administrative Procedure Act For the reasons' discussed above, we believe that the Staff should not seek confirming guidance from the Commission, and the l

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JF SH AW, PITT M AN, PoTTs & TROWBRIDGE A pantNgesusp eNCLUDeNO NCFE SSONAL COe*0eAfiONS i

Commission should not restrict the discretion of the. Staff by preselecting one of the three_ funding period' options, but should instead allow case-by-case consideration of what is appropriate.

Only by.considering the special circumstances in each case can the NRC determine what is_necessary to-provide reasonable'

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assurance of funding without imposing undue burdens.

If, however, the Commission is inclined'to dictate a generic funding. schedule for prematurely shut down plants, it may only do so by rulemaking.

The preselection of one of the suggested options _would establish a substantive obligation to be imposed on a class of licensee.

As discussed above, there is no absolute requirement under the current regulations that a licensee have all funds-accumulated by cessation of operations, five years:

thereafter, or by the end of the license term.

Accordingly, the options cannot be viewed as interpretative.

incread, any preselection would be the establishment of a " binding norm" for a situation not addressed by the current rule.

'The courts have held that a statement that. establishes a substantive standard -- a binding norm -- is a substantive rule.

Pacific Gas and Electric Co.

v.

FPC, 506 F.2d 33, 38'(D.C. Cir.

1974).

Similarly, a statement that limits the discretion of an

. official is a substantive rule.

Limerick Ecolooy Action, Inc. v.

NRC, 869 F.2d 719, 734 (3d Cir. 1989).

'Under the APA, absent i

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